These regulations propose guidance under sections 6048, 6677 and 6039F of the Internal Revenue Code relating to information reporting on transactions with foreign trusts and on large foreign gifts. This document also contains proposed regulations under section 643(i) relating to loans from or uncompensated use of property of foreign trusts, as well as proposed amendments to the regulations under section 679 relating to foreign trusts having one or more U.S. beneficiaries.